CFR 111 Re-Write NPRM Raises Concerns in Brokerage Community

Evey Hwang, CBFANC President

On sufficient supervision:

What is Customs definition? A large broker company is not the same as small.
Presumption of guilty is the tone of language current. Example, if broker response is expected 48-72 hours, but if voicemail or email fell to wrong person.
Due process

Discussion on National Permit was just as troubling. Do we rely on one broker compliance versus individual port? Reporting requirements. And what is our recourse if brokers does not have due process.
Your attention to this 111 rewrite is needed because if it goes forward in current language, brokers will be allowing Customs to define our business and diminish due process. Comment period ends August 7, 2020. Take time to provide direct or please forward to CBFANC for collective response with national brokers.


CFR 111 Re-Write NPRM Raises Concerns in Brokerage Community Evey Hwang, CBFANC President On sufficient supervision: What is Customs definition? A large broker company is not the same as small. Presumption of guilty is the tone of language current. Example, if broker response is expected 48-72 hours, but if voicemail or email fell to wrong person. Due process Discussion on National Permit was just as troubling. Do we rely on one broker compliance versus individual port? Reporting requirements. And what is our recourse if brokers does not have due process. Your attention to this 111 rewrite is needed because if it goes forward in current language, brokers will be allowing Customs to define our business and diminish due process. Comment period ends August 7, 2020. Take time to provide direct or please forward to CBFANC for collective response with national brokers.
CBFANC Newsletter - copy of June 2020 - Info Expeditor